Introduction

Confidentiality is often referred to as an "expectation" of the parties in international commercial arbitration. However, as one of the earlier discussions of the topic already noted " Parties may be astonished to find, when they actually test the matter, that the rule of confidentiality is not reliable ". Most arbitration laws are silent on the issue. With the notable exception of England, there are few court decisions dealing with the confidentiality of the arbitral process. It is, therefore, not surprising that the existence and scope of possible ...